Setting the Record Straight A
nother very important item that is often a common mistake: recordkeeping. This is something that not only shows up
on audits, but it is also important for the everyday function of your business. From our experience working with auto recyclers, paperwork
is often the aspect of business that is in need of the most tweaking when we are hired by a new client. There are a few exceptions, but all-in-all the recordkeeping systems are not complete, organized, or user-friendly. We have developed a system that seems to work well to help our folks keep track of the necessary information in a simple, user-friendly manner.
Binder System The system we use applies specifically to your Storm Water
Pollution Prevention Plan (SWPPP) and Spill Prevention Control and Countermeasure (SPCC) Plan. Inside the binders are all of the necessary forms along with space to store all of your pertinent documents. For example, if you sell a drum of used oil, you turn to the used oil tab of your SWPPP binder and store a copy of the receipt in that section. For our clients, we keep redundant, electronic copies of the binders at our office so if something is lost or damaged
we can recreate our clients’ system. We perform quarterly update checks to ensure that recordkeeping is up-to-date. We encourage you to keep records of all activities so that in the event you are asked you can produce documentation to support your processes. There are often more requirements for internal tracking than there are requirements that are submitted to a regulatory agency. None of the requirements are particularly difficult. The difficulty is keeping up with the large number of requirements and developing a system that makes the compliance program run effectively. For sake of discussion, let’s talk about storm water. Storm water permits have several documents that are required to be submitted to the regulatory agency, such as the Notice of Intent, Storm Water Sampling, and Annual Reporting. However, items such as Quarterly Visual Wet Weather Inspections and Annual SWPPP Training documentation are not required to be submitted to a regulatory agency. Therefore, we often see that items required for submittal are completed while the other documentation falls to the wayside.
Staying on Course What are some ways to ensure that your records are organized and required documentation is completed in a timely manner?
62 // September-October 2021
Automotive Recycling
COMPLIANCE
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